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HomeMy WebLinkAbout07-5715 SHAPIRO & KREISMAN, LLC BY: CHRISTOPHER A. DENARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-23867 REO Properties Corporation PLAINTIFF vs. Tracey Lee Milakovic, Kevin M. Milakovic And Occupants 4727 East Trindle Road Mechanicsburg, PA 17055 DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Q7 - 6715 Civi ( IeTY4 CIVIL ACTION - EJECTMENT 21000 NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIEREDEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES,USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LADEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIAESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE ENFORMA ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS ENCONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE,LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SINPREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ESPEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO OSUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENEABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCIONSE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDECONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 05-23867 SHAPIRO & KREISMAN, LLC BY: CHRISTOPHER A. DENARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-23867 REO Properties Corporation PLAINTIFF vs. Tracey Lee Milakovic, Kevin M. Milakovic And Occupants 4727 East Trindle Road Mechanicsburg, PA 17055 DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 9-Vis'6??j --TZ CIVIL ACTION - EJECTMENT Plaintiff hereby complains against Defendants as follows: Plaintiff, REO Properties Corporation ("Plaintiff'), a corporation, has an office located at 1665 Palm Beach Lakes, Suite 105, West Palm Beach, FL 33401, and is properly conducting business in the Commonwealth of Pennsylvania. 2. Defendants are Tracey Lee Milakovic, Kevin M. Milakovic and Occupants ("Defendants") and they reside at 4727 East Trindle Road, Mechanicsburg, PA 17055 (the "Premises") 3. The Premises, which is where the ejectment is to take place, is located at 4727 East Trindle Road, Mechanicsburg, PA 17055. A true and correct copy of the legal description of the Premises, is attached hereto, incorporated herein by reference, and marked as Exhibit "A." 4. The Premises were sold at Sheriffs sale by the Sheriff of Cumberland County, Pennsylvania, after due advertisement and according to law, under and by virtue of a Writ of Execution issued to satisfy a Judgment in Mortgage Foreclosure entered in the Court of Common Pleas of Cumberland County, Pennsylvania, at the suit of. REO Properties Corporation v. Tracey Lee Milakovic and Kevin M. Milakovic. 5. The case number of said Judgment is: 05-5012-CIVIL TERM 6. The Sheriffs sale was held on: September 5, 2007. 7. Kevin M. Milakovic & Tracey Lee Milakovic were the previous owners of the Premises by virtue of a Deed dated August 26, 1999, and recorded in the Office of the Recorder of Deeds for Cumberland County, Pennsylvania on September 1, 1999, in Deed Book 206, Page 1130, Cumberland County, Pennsylvania. 8. Plaintiff purchased the Premises at the Sheriffs sale. 9. Plaintiff acquired valid title to the Premises on the date of and by virtue of said Sheriffs sale. 10. Plaintiff is still the real owner of said Premises and is entitled to immediate possession of the Premises. 11. The Deed in favor of REO Properties Corporation was recorded in the Office of the Recorder of Deeds in and for Cumberland County as Instrument no. 200736402 on September 19, 2007. A true and correct copy of the Sheriff's Deed, is attached hereto, incorporated herein by reference, and marked as Exhibit "B." 12. Said Deed is a matter of public record and therefore, is incorporated by reference herein as though fully set forth at length. 13. The persons in possession of the Premises are believed to be the Defendants in this action who are occupying the Premises without right and without claim to title. 14. Plaintiff is entitled to immediate possession of the Premises. WHEREFORE, Plaintiff demands judgment, in ejectment, for immediate possession of the Premises, issuance of a Writ of Possession and a judgment of its costs and disbursements in this action. Respectfully submitted, SHAPIRO & KREISMAN, LLC Date: BY: Christopher A. DeNardo, Esquire Attorney for Plaintiff File # 05-23867 ALL THAT CERTAIN tract of land situate in Hampden Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Ernest J. Walker, Professional Engineer, dated September 5, 1968, as follows: BEGINNING at a point in the middle of Trindle Road (formerly known as Trindle Spring Road) at the Easterly line of property now or late of Everett L. Burr, et al; thence along said property North 26 degrees 30 minutes West 259.1 feet to an iron pipe in line of land now or late of Mary Keebaugh; thence along said land North 73 degrees 49 minutes 25 seconds East 66.12 feet to an iron pipe, a corner of property now or late of Charles W. Herbine; thence along the same South 26 degrees 30 minutes East 247.27 feet to a point in the middle of Trindle Road aforesaid; thence along the center there of South 63 degrees 30 minutes West 65 feet to the place of BEGINNING. HAVING THEREON ERECTED a One and One-Half story frame dwelling known as No. 4727 Trindle Road. BEING the same premises which Frances Lee Bennett, a single person, by Deed dated August 26, 1999 and recorded in the Cumberland County Recorder of Deeds Office on September 1, 1999 in Deed Book 206, Page 1130, granted and conveyed unto Kevin M. Milakovic and Tracy Lee Milakovic, his wife, as Tenants by the Entireties. EXHIBIT "A" 36qu?_e Tax Parcel No. 10-22-0527-075 Know all Men by these Presents 7-S _ z C l . That I, R. Thomas Kline, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $1.00, (One Dollar), to me in hand paid, do hereby grant and convey to REO Properties Corporation Real Estate Sale No. 59 Writ No. 2005-5012 Civil Term REO Properties Corporation VS Tracey Lee Milakovic and Kevin M. Milakovic Atty. Lauren R. Tabas DESCRIPTION ALL THAT CERTAIN tract of land situate in Hampden Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Ernest J. Walker, Professional Engineer, dated September 5, 1968, as follows: BEGINNING at a point in the middle of Trindle Road (formerly known as Trindle Spring Road) at the Easterly line of property now or late of Everett L. Burr, et al; thence along said property North 26 degrees 30 minutes West 259.1 feet to an iron pipe in line of land now or late of Mary Keebaugh; thence along said land North 73 degrees 49 minutes 25 seconds East 66.12 feet to an iron pipe, a corner of property now or late of Charles W. Herbine; thence along the same South 26 degrees 30 minutes East 247.27 feet to a point in the middle of Trindle Road aforesaid; thence along the center there of South 63 degrees 30 minutes West 65 feet to the place of BEGINNING. HAVING THEREON ERECTED a One and One-Half story frame dwelling known as No. 4727 Trindle Road. BEING the same premises which Frances Lee Bennett, a single person, by Deed dated August 26, 1999 and recorded in the Cumberland County Recorder of Deeds Office on September 1, 1999 in Deed Book 206, Page 1] 30, granted and conveyed unto Kevin M. Milakovic and Tracy Lee Milakovic, his wife, as Tenants by the Entireties. E XK; 6 .} 1% 11 The same having been sold by me to the said grantee on the 5th day of September Anno Domini Two Thousand and Seven (2007) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 22nd day of May Anno Domini 2007 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Five (2005) Number 5012 at the suit of REO Properties Corporation against Tracey Lee Milakovic and Kevin M. Milakovic. In Witness Wereof, I have hereunto affixed my signature this 17th day of September Anno Domini Two Thousand and Seven (2007) Thomas 1 line, Sheriff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, Curitis Long, Prothonotaryof the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared R. Thomas Kline, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 17th day of Sept. Anno Domini Two Thousand and Seven (2007) ?+w.^ 3? ? rr- "tea U 11 N.; //?,'A &?? - Protlfonotary / -- I hereby certify that the residence And Post Office address of the Within Grantee is 1665 Palm Beach Lakes, Suite 105 West Palm Beach, FL 33401 Solicitor ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY I COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200736402 Recorded On 9/19/2007 At 9:26:24 AM * Instrument Type - DEED-SHERIFF'S Invoice Number - 4814 User ID - MBL * Grantor - MILAKOVIC, TRACEY LEE * Grantee - REO PROPERTIES CORP * Customer - CUMBERLAND COUNTY SHERIFF * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $10.00 JUSTICE RECORDING FEES - $12.50 RECORDER OF DEEDS AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $39.50 * Total Pages - 5 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA ?y ?f CUq fed r 9 a /° RECORDER O D EDS v ? Sao * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 1111111111111111111111111 VERIFICATION Christopher A. DeNardo hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to make this Verification, and that the statements made in the foregoing Complaint in Ejectment are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. SHAPIRO & KREISMAN, LLC BY: Christopher A. DeNardo, Esquire Dated: ?? ?j -0 ?. Attorney for Plaintiff 00 '' - f f= ? M1 -g-S SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-05715 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND REO PROPERTIES CORPORATION VS MILAKOVIC TRACEY LEE ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT OCCUPANT but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , the within named DEFENDANT , OCCUPANT NOT FOUND , as to 4727 EAST TRINDLE ROAD MECHANICSBURG, PA 17055 THERE WERE NO OTHER OCCUPANTS. Sheriff's Costs: Docketing Service Not Found Surcharge (4- /)10t7 So answers: 6.00 .00 5.00 R. Th s Kline 10.00 Sheriff of Cumberland County .00 21.00 SHAPIRO & KREISMAN 10/15/2007 Sworn and Subscribed to before me this day of A. D. CASE NO: 2007-05715 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND REO PROPERTIES CORPORATION VS MILAKOVIC TRACEY LEE ET AL VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon MILAKOVIC TRACEY LEE the DEFENDANT at 1416:00 HOURS, on the 12th day of October , 2007 at 4727 EAST TRINDT.F RnAT) MECHANICSBURG, PA 17055 KEVIN MILAKOVIC, HUSBAND by handing to a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 12.48 Affidavit .00 Surcharge 10.00 00 40 .48 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 10/15/2007 SHAPIRO & KREISMAN By : Deputy Sheriff of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2007-05715 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND REO PROPERTIES CORPORATION VS MILAKOVIC TRACEY LEE ET AL VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon MILAKOVIC KEVIN M the DEFENDANT , at 1416:00 HOURS, on the 12th day of October , 2007 at 4727 EAST TRINDLE ROAD MECHANICSBURG, PA 17055 by handing to KEVIN MILAKOVIC a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing Service 6.00 .00 Affidavit . 00 Surcharge 10.00 R. Thomas Kline .00 , l?lb?/a? ? 16.00 10/15/2007 7 SHAPIRO & KREISMAN Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. SHAPIRO & KREISMAN, LLC BY: CHRISTOPHER A. DENARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-23867 REO Properties Corporation PLAINTIFF vs. Tracey Lee Milakovic, Kevin M. Milakovic And Occupants 4727 East Trindle Road Mechanicsburg, PA 17055 DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Or1- 5715 ivi l (t4-,u CIVIL ACTION - EJECTMENT 21000 NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street ; L COPY FROM F F-WRD Carlisle, PA 17013 71 P 3166 in Tfttlmony wherW, I here unto set my han' and tale sW of said Court at Car11S18 Pa. thono rv NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIEREDEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES,USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LADEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIAESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE ENFORMA ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS ENCONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE,LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SINPREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ESPEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO OSUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENEABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCIONSE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDECONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 05-23867 SHAPIRO & KREISMAN, LLC BY: CHRISTOPHER A. DENARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-23867 REO Properties Corporation PLAINTIFF vs. Tracey Lee Milakovic, Kevin M. Milakovic And Occupants 4727 East Trindle Road Mechanicsburg, PA 17055 DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION - EJECTMENT Plaintiff hereby complains against Defendants as follows: Plaintiff, REO Properties Corporation ("Plaintiff'), a corporation, has an office located at 1665 Palm Beach Lakes, Suite 105, West Palm Beach, FL 33401, and is properly conducting business in the Commonwealth of Pennsylvania. 2. Defendants are Tracey Lee Milakovic, Kevin M. Milakovic and Occupants ("Defendants") and they reside at 4727 East Trindle Road, Mechanicsburg, PA 17055 (the "Premises") 3. The Premises, which is where the ejectment is to take place, is located at 4727 East Trindle Road, Mechanicsburg, PA 17055. A true and correct copy of the legal description of the Premises, is attached hereto, incorporated herein by reference, and marked as Exhibit "A." 4. The Premises were sold at Sheriffs sale by the Sheriff of Cumberland County, Pennsylvania, after due advertisement and according to law, under and by virtue of a Writ of Execution issued to satisfy a Judgment in Mortgage Foreclosure entered in the Court of Common Pleas of Cumberland County, Pennsylvania, at the suit of REO Properties Corporation v. Tracey Lee Milakovic and Kevin M. Milakovic. 5. The case number of said Judgment is: 05-5012-CIVIL TERM 6. The Sheriffs sale was held on: September 5, 2007. 7. Kevin M. Milakovic & Tracey Lee Milakovic were the previous owners of the Premises by virtue of a Deed dated August 26, 1999, and recorded in the Office of the Recorder of Deeds for Cumberland County, Pennsylvania on September 1, 1999, in Deed Book 206, Page 1130, Cumberland County, Pennsylvania. 8. Plaintiff purchased the Premises at the Sheriffs sale. 9. Plaintiff acquired valid title to the Premises on the date of and by virtue of said Sheriffs sale. 10. Plaintiff is still the real owner of said Premises and is entitled to immediate possession of the Premises. 11. The Deed in favor of REO Properties Corporation was recorded in the Office of the Recorder of Deeds in and for Cumberland County as Instrument no. 200736402 on September 19, 2007. A true and correct copy of the Sheriff's Deed, is attached hereto, incorporated herein by reference, and marked as Exhibit "B." 12. Said Deed is a matter of public record and therefore, is incorporated by reference herein as though fully set forth at length. 13. The persons in possession of the Premises are believed to be the Defendants in this action who are occupying the Premises without right and without claim to title. 14. Plaintiff is entitled to immediate possession of the Premises. WHEREFORE, Plaintiff demands judgment, in ejectment, for immediate possession of the Premises, issuance of a Writ of Possession and a judgment of its costs and disbursements in this action. Respectfully submitted, SHAPIRO & KREISMAN, LLC Date: BY: Christopher A. DeNardo, Esquire Attorney for Plaintiff File # 05-23867 ALL THAT CERTAIN tract of land situate in Hampden Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Ernest J. Walker, Professional Engineer, dated September 5, 1968, as follows: BEGINNING at a point in the middle of Trindle Road (formerly known as Trindle Spring Road) at the Easterly line of property now or late of Everett L. Burr, et al; thence along said property North 26 degrees 30 minutes West 259.1 feet to an iron pipe in line of land now or late of Mary Keebaugh; thence along said land North 73 degrees 49 minutes 25 seconds East 66.12 feet to an iron pipe, a corner of property now or late of Charles W. Herbine; thence along the same South 26 degrees 30 minutes East 247.27 feet to a point in the middle of Trindle Road aforesaid; thence along the center there of South 63 degrees 30 minutes West 65 feet to the place of BEGINNING. HAVING THEREON ERECTED a One and One-Half story frame dwelling known as No. 4727 Trindle Road. BEING the same premises which Frances Lee Bennett, a single person, by Deed dated August 26, 1999 and recorded in the Cumberland County Recorder of Deeds Office on September 1, 1999 in Deed Book 206, Page 1130, granted and conveyed unto Kevin M. Milakovic and Tracy Lee Milakovic, his wife, as Tenants by the Entireties. EXHIBIT "A" Tax Parcel No. 10-22-0527-075 Know all Men by these Presents That I, R. Thomas Kline, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $1.00, (One Dollar), to me in hand paid, do hereby grant and convey to REO Properties Corporation Real Estate Sale No. 59 Writ No. 2005-5012 Civil Term REO Properties Corporation VS Tracey Lee Milakovic and Kevin M. Milakovic Atty. Lauren R. Tabas DESCRIPTION ALL THAT CERTAIN tract of land situate in Hampden Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Ernest J. Walker, Professional Engineer, dated September 5, 1968, as follows: BEGINNING at a point in the middle of Trindle Road (formerly known as Trindle Spring Road) at the Easterly line of property now or late of Everett L. Burr, et al; thence along said property North 26 degrees 30 minutes West 259.1 feet to an iron pipe in line of land now or late of Mary Keebaugh; thence along said land North 73 degrees 49 minutes 25 seconds East 66.12 feet to an iron pipe, a corner of property now or late of Charles W. Herbine; thence along the same South 26 degrees 30 minutes East 247.27 feet to a point in the middle of Trindle Road aforesaid; thence along the center there of South 63 degrees 30 minutes West 65 feet to the place of BEGINNING. HAVING THEREON ERECTED a One and One-Half story frame dwelling known as No. 4727 Trindle Road. BEING the same premises which Frances Lee Bennett, a single person, by Deed dated August 26, 1999 and recorded in the Cumberland County Recorder of Deeds Office on September 1, 1999 in Deed Book 206, Page 1] 30, granted and conveyed unto Kevin M. Milakovic and Tracy Lee Milakovic, his wife, as Tenants by the Entireties. E 4y, K ; 6 ;? "8, , The same having been sold by me to the said grantee on the 5th day of September Anno Domini Two Thousand and Seven (2007) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 22nd day of May Anno Domini 2007 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Five (2005) Number 5012 at the suit of REO Properties Corporation against Tracey Lee Milakovic and Kevin M. Milakovic. In Witness Wereof, I have hereunto affixed my signature this 17th day of September Anno Domini Two Thousand and Seven (2007) OTh3omas I line, Sheriff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, curitis Long, Prothonotaryof the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared R. Thomas Kline, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 17th day of Sept. Anno Domini Two Thousand and Seven (2007) • . _ -A.In Protlionotary I hereby certify that the residence And Post Office address of the Within Grantee is 1665 Palm Beach Lakes, Suite 105 West Palm Beach, FL 33401 Solicitor ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200736402 Recorded On 9/19/2007 At 9:26:24 AM * Instrument Type - DEED-SHERIFF'S Invoice Number - 4814 User ED - MBL * Grantor - MILAKOVIC, TRACEY LEE * Grantee - REO PROPERTIES CORP * Customer - CUMBERLAND COUNTY SHERIFF * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $10.00 JUSTICE RECORDING FEES - $12.50 RECORDER OF DEEDS AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $39.50 * Total Pages - 5 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER O D EDS trao * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 11111111111111111111111111 VERIFICATION Christopher A. DeNardo hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to make this Verification, and that the statements made in the foregoing Complaint in Ejectment are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unworn falsification to authorities. SHAPIRO & KREISMAN, LLC BY: Christopher A. DeNardo, Esquire Dated: ?J ?(? Attorney for Plaintiff SERVE SHAPIRO & KREISMAN, LLC BY: CHRISTOPHER A. DENARDO, ESQUIRE ATTORNEY I. D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-23867 REO Properties Corporation PLAINTIFF VS. Tracey Lee Milakovic, Kevin M. Milakovic And Occupants 4727 East Trindle Road Mechanicsburg, PA 17055 DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-5715 Civil Term PRAECIPE FOR JUDGMENT FOR POSSESSION FOR FAILURE TO ANSWER Enter Judgment for immediate possession of the Premises located at: 4727 East Trindle Road, Mechanicsburg, PA 17055, in favor of Plaintiff and against the Defendants above captioned for failure to file an answer to Plaintiffs Complaint within 20 days from service of the Complaint. BY: 6?n?? Christopher A. DeNardo, Esquire Attorney for Plaintiff AND NOW, judgment for immediate possession of the Premises located at 4727 East Trindle Road, Mechanicsburg, PA 17055 is entered in favor of the Plaintiff and against the Defendant(s). S " P. " ?046 Wo. Prothy. 1. SHAPIRO & KREISMAN, LLC BY: CHRISTOPHER A. DENARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-23867 REO Properties Corporation PLAINTIFF vs. Tracey Lee Milakovic, Kevin M. Milakovic and Occupants DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-5715 Civil Term CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto, November 6, 2007, to: Tracey Lee Milakovic 4727 E. Trindle Rd. Mechanicsburg, PA 17055 Kevin M. Milakovic 4727 E. Trindle Rd. Mechanicsburg, PA 17055 Occupants 4727 E. Trindle Rd. Mechanicsburg, PA 17055 Laraine Colwell, Legal Assistant SHAPIRO & KREISMAN, LLC SHAPIRO & KREISMAN, LLC BY: CHRISTOPHER A. DENARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-23867 REO Properties Corporation PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. Tracey Lee Milakovic, Kevin M. Milakovic and Occupants DEFENDANTS NO: 07-5715 Civil Term NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Tracey Lee Milakovic DATE OF NOTICE: November 6, 2007 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNA PODRA, SIN NECESIDAD DE COMPARARECER USTED IN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA. USTED PUEDE PERDER BIENES Y OTROS DERECHOS IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE. SI USTED NO TIENE ABOGADO O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSITENCIA LEGAL: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Tracey Lee Milakovic 4727 E. Trindle Rd. Mechanicsburg, PA 17055 Kevin M. Milakovic 4727 E. Trindle Rd. Mechanicsburg, PA 17055 Occupants 4727 E. Trindle Rd. Mechanicsburg, PA 17055 Christopher A. DeNardo, Esquire Attorney for Plaintiff SHAPIRO & KREISMAN, LLC BY: CHRISTOPHER A. DENARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-23867 REO Properties Corporation PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs. Tracey Lee Milakovic, Kevin M. Milakovic and Occupants DEFENDANTS NO: 07-5715 Civil Term NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Kevin M. Milakovic DATE OF NOTICE: November 6, 2007 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNA PODRA, SIN NECESIDAD DE COMPARARECER USTED IN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA. LISTED PUEDE PERDER BIENES Y OTROS DERECHOS IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE. SI USTED NO TIENE ABOGADO O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSITENCIA LEGAL: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Tracey Lee Milakovic 4727 E. Trindle Rd. Mechanicsburg, PA 17055 Kevin M. Milakovic 4727 E. Trindle Rd. Mechanicsburg, PA 17055 Occupants 4727 E. Trindle Rd. Mechanicsburg, PA 17055 Z?? Christopher A. DeNardo, Esquire Attorney for Plaintiff SHAPIRO & KREISMAN, LLC BY: CHRISTOPHER A. DENARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-23867 REO Properties Corporation PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. Tracey Lee Milakovic, Kevin M. Milakovic and Occupants DEFENDANTS NO: 07-5715 Civil Term NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Occupants DATE OF NOTICE: November 6, 2007 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. A NOTIFICACION IMPORTANTE LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNA PODRA, SIN NECESIDAD DE COMPARARECER USTED IN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA. LISTED PUEDE PERDER BIENES Y OTROS DERECHOS IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE. SI USTED NO TIENE ABOGADO O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSITENCIA LEGAL: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Tracey Lee Milakovic 4727 E. Trindle Rd. Mechanicsburg, PA 17055 Kevin M. Milakovic 4727 E. Trindle Rd. Mechanicsburg, PA 17055 Occupants 4727 E. Trindle Rd. Mechanicsburg, PA 17055 Christopher A. DeNardo, Esquire Attorney for Plaintiff SHAPIRO & KREISMAN, LLC BY: CHRISTOPHER A. DENARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-23867 REO Properties Corporation PLAINTIFF vs. Tracey Lee Milakovic, Kevin M. Milakovic And Occupants 4727 East Trindle Road Mechanicsburg, PA 17055 DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 -T - 715 0. ' P" I 7-?zrm AFFIDAVIT OF NON-MILITARY SERVICE STATE OF FLORIDA COUNTY OF ORANGE s.s.: THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above named Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Tracey Lee Milakovic Age: Over 18 Residence: 4727 East Trindle Road, Mechanicsburg, PA 17055 Employment: Unknown Defendant: Kevin M. Milakovic Age: Over 18 Residence: 4727 East Trindle Road, Mechanicsburg, PA 17055 Employment: Unknown Defendant: OCCUPANT Age: Unknown Residence: 4727 East Trindle Road, Mechanicsburg, PA 17055 Employment: Unknown Name: ANNA V. JI ENEZ-REYES Title: FORECLOSYRE FACILITATOR Company: OCW LOAN SERVICINT LLC Sworn to and s d bef e his d y of 2007. Notary Public 05-23867 _ ??rF HEATHER A. SNIDER 5x: MY C&A.vssfoN # DD 693114 EXPIRB July 9, 2011 Bonded Thru t,ota' Pubfic Underwriters SHAPIRO & KREISMAN, LLC BY: CHRISTOPHER A. DENARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-23867 REO Properties Corporation PLAINTIFF VS. Tracey Lee Milakovic, Kevin M. Milakovic And Occupants 4727 East Trindle Road COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-5715 Civil Term Mechanicsburg, PA 17055 DEFENDANTS CERTIFICATION OF ADDRESS I hereby certify that the correct addresses of the judgment creditor (Plaintiff) and that the last known address of the judgment debtors (Defendants) are as above. SHAPIRO & KREISMAN, LLC BY: Christopher A. DeNardo, Esquire Attorney for Plaintiff SHAPIRO & KREISMAN, LLC BY: CHRISTOPHER A. DENARDO, ESQUIRE ATTORNEY I. D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-23867 REO Properties Corporation PLAINTIFF VS. Tracey Lee Milakovic, Kevin M. Milakovic And Occupants 4727 East Trindle Road Mechanicsburg, PA 17055 DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-5715 Civil Term CERTIFICATE OF SERVICE I, Christopher A. Denardo hereby certify that I have served true and correct copies of the attached papers upon the following persons named herein at their last known address or their attorney of record by regular mailing, postage pre-paid, as follows, on November 19, 2007: Tracey Lee Milakovic 4727 E. Trindle Rd. Mechanicsburg, PA 17055 Kevin M. Milakovic 4727 E. Trindle Rd. Mechanicsburg, PA 17055 Current Occupant 4727 East Trindle Road Mechanicsburg, PA 17055 BY. Christopher A. DeNardo, Esquire Attorney for Plaintiff - 9A c> OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Curtis R. Long, Prothonotary TO: Tracey Lee Milakovic 4727 East Trindle Road Mechanicsburg, PA 17055 REO Properties Corporation PLAINTIFF VS. Tracey Lee Milakovic, Kevin M. Milakovic And Occupants 4727 East Trindle Road Mechanicsburg, PA 17055 DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-5715 Civil Term NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Curtis R. Long Prothonotary [XX] Judgment by Default [XX] Judgment for Possession IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY CHRISTOPHER A. DENARDO BY CALLING (610) 278-6800 SHAPIRO & KREISMAN, LLC BY: CHRISTOPHER A. DENARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-23867 REO Properties Corporation PLAINTIFF VS. Tracey Lee Milakovic, Kevin M. Milakovic And Occupants 4727 East Trindle Road COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-5715 Civil Term Mechanicsburg, PA 17055 DEFENDANTS PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Kindly issue a Writ of Possession in the above matter for property located at 4727 East Trindle Road, Mechanicsburg, PA.17055 as more fully described in the Complaint. (Costs to be added) $ SHAPIRO & KREISMAN, LLC CHRISTOPHER A. DENARDO, ESQUIRE !?3 ?i -Eta lK. n -? oa ..., -? rTi 'b+ O Q O 8 a s c-? D 73 W2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REO PROPERTIES CORPORATION VS. No. 07-5715 Civil Term_ TRACEY LEE MILAKOVIC KEVIN M. MILAKOVIC and OCCUPANTS Costs Attorney's $ 193.68 Plaintiff's $ Prothonotary $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to.deliver possession of the following described property to: (Plaintiff (s)) REO PROPERTIES CORPORATION being: (Premises as follows): 4727 EAST TRINDLE ROAD, MECHANCSBURG, PA 17055 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. In/ . P- CtL?)-C& or lCultis R. Long, Prothonotary, Common Pleas Court of Cumberland County, PA Date 12/20/07 (Seal) 2 oil No 07-5715 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REO PROPERTIES CORPORATION TRACEY LEE MILAKOVIC KEVIN M. MILAKOVIC and OCCUPANT VS. WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 193.68 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: CHRISTOPHER A. DENARDO, ESQUIRE SHAPIRO & KREISMAN, LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 610-278-6800 By virtue of this writ, on the named appurtenances, and Sworn and subscribed to before me this Day of , Attorney for Plaintiff (s) Where papers may be served day of . I caused the within to have possession of the premises described with the Prothonotary So Answers, Sheriff By Deputy SHAPIRO & KREISMAN, LLC BY: CHRISTOPHER A. DENARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-23867 REO Properties Corporation PLAINTIFF VS. Tracey Lee Milakovic, Kevin M. Milakovic And Occupants 4727 East Trindle Road Mechanicsburg, PA 17055 DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-5715 Civil Term Xssor PRAECIPE TOE WRIT OF POSSESSION TO THE PROTHONOTARY: Kindly issue a Writ of Possession in the above matter for property located at 4727 East Trindle Road, Mechanicsburg, PA 17055 as more fully described in the Complaint. (Costs to be added) $ SHAPIRO & KREISMAN, LLC CHRISTOPHER A. DENARDO, ESQUIRE SL a a ? R, . - W O ?? Ooo Q ?o ? ?O 7'. F ? W 'rj ? n O ?^ M? kD ip y lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REO PROPERTIES CORPORATION VS. No. 07-5715 Civil Term TRACEY LEE MILAKOVIC, KEVIN M. MILAKOVIC, and OCCUPANTS 4727 East Trindle Road Mechanicsburg, PA 17055 Costs Attorney's $ 162.28 Plaintiff's $ Prothonotary $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) REO PROPERTIES CORPORATION being: (Premises as follows): 4727 EAST TRINDLE ROAD, MECHANICSBURG, PA 17055 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. Curtis R. Long, Prot otary, Common Pleas, ourt of Cumb land County, PA Date 2/05/08 (Seal) AD -.. 2of2 No 07-5715 Civil Term By virtue of this writ, on the day of I caused the within named , to have possession of the premises described with the appurtenances, and vs. Attorney for Plaintiff (s) Where papers may be served Sworn and subscribed to before me this Day of , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REO PROPERTIES CORPORATION TRACEY LEE MILAKOVIC, KEVIN M. MILAKOVIC, and OCCUPANT WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 162.28 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: CHRISTOPHER A. DENARDO, ESQUIRE SHAPIRO & KREISMAN, LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 610-278-6800 Prothonotary So Answers, Sheriff By Deputy i . By virtue of this writ, on the day of . I caused the within named to have possession of the premises described with the appurtenances, and Writ o Possession re urne Swom and subscribed to before me this Day of , Jf ,r1 Ole, Sheriff Sheriff's Return: Advance Costs: 250.00 Sheriff's Costs: 60.80 Docketing 18.00 Surcharge 30.00 Prothy 2.00 Poundage 1.20 Refunded to Atty on 1/18/08 Milage 9.60 ? ?/d 3/O P 60.80 9Z ?Z d L Z 330 LOOZ ed ?lNno ?31?3HS 3Ni ?U 3;II ??U c cA v U? ?l03 7?s 2of2 No 07-5715 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REO PROPERTIES CORPORATION VS. TRACEY LEE MILAKOVIC KEVIN M. MILAKOVIC and OCCUPANT WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 193.68 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: CHRISTOPHER A. DENARDO, ESQUIRE SHAPIRO & KREISMAN, LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 610-278-6800 Attorney for Plaintiff (s) By virtue of this writ, on the named appurtenances, and Where papers may be served day of , . I caused the within _, to have possession of the premises described with the Sworn and subscribed to before me this Day of , Prothonotary So Answers, Sheriff By Deputy lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REO PROPERTIES CORPORATION VS. No. 07-5715 Civil Term TRACEY LEE MILAKOVIC KEVIN M. MILAKOVIC and OCCUPANTS Costs Attorney's $ 193.68 Plaintiff's $ Prothonotary $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) REO PROPERTIES CORPORATION being: (Premises as follows): 4727 EAST TRINDLE ROAD, MECHANCSBURG, PA 17055 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. 5 lCtIrtis R. Long, Prothonotary, Common Pleas Court of Cumberland County, PA Date 12/20/07 (Seal) Byfvirtue of this writ, on the 3 r d ,day of Ap i L 2 0 0 8 I caused the within named _R EO Proner t i P g C'or'n ; to have possession of the premises described O(t#X*X W fik"&X/a7?7 F"a?t Tri nrl.l P RRa? Marhani cs il-ro PA 17055 So Answer Sworn and subscribed to before me this Day of. heri V By 0- Sheriff's Return: Docketing 118.00 Advance Costs: 250.00 Surcharge 36,06 Sheriff's Costs:102.00 Poundage 32), dO fib- . Milage 20.00 Possession 30.00 ProthyRefunded to Atty on 4/14/08 ? L/`d Q?b P ?. 102.00 L fi cy q_ 933 8001 Vd /? iy31 -13183NS ?y1 Lir'; 0 ?;.?f? a0 r Ch l.3sir , 2 Cp2(`? d 2of2 No 07-5715 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REO PROPERTIES CORPORATION TRACEY LEE MILAKOVIC, KEVIN M. MILAKOVIC, and OCCUPANT VS. WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 162.28 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: CHRISTOPHER A. DENARDO, ESQUIRE SHAPIRO & KREISMAN, LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 610-278-6800 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the day of I caused the within named , to have possession of the premises described with the appurtenances, and Sworn and subscribed to before me this Day of Prothonotary So Answers, Sheriff By Deputy